ML20002A214
| ML20002A214 | |
| Person / Time | |
|---|---|
| Site: | 07001308 |
| Issue date: | 10/30/1980 |
| From: | Rooney M, Szwajkowski R GENERAL ELECTRIC CO., MAYER, BROWN & PLATT |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| NUDOCS 8011050171 | |
| Download: ML20002A214 (3) | |
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Dated:
October 30, 1980 A.
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 3
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LCNDO IN THE MATTER OF GENERAL
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Docket No. 70-1308
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s Consideration of Renewal of
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Materials License No. SNM-1265
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Issued to G.E. Morris Operation )
Fuel Storage Installation.
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ANSWER OF GENERAL ELECTRIC TO MOTION TO STAY PROCEEDINGS OF THE STATE OF ILLINOIS General Electric Company (" General Electric") submits this memorandum, pursuant to 10 C.F.R. 52.730(c), as its answer to the Motion to Stay Proceedings of the State of Illinois
(" Illinois"), which was filed on October 15, 1980.
General Electric opposes Illinois' motion and states as follows:
1.
In the first place, Illinois has pointed to no reason to Gelay this Board's consideration of General Electric's motions for sanctions filed on October 9 and 13 against Intervenors Rorem, et al. and Illinois.
Those motions do not address the substance of the license renewal application and are unaffected by promulgation of 10 C.F.R.,
Part 72, which Illinois puts forth as the major reason to stay this entire proceeding.
Those motions are based upon the improper conduct of both intervenors in failing to comport themselves in good faith as parties to the proceeding.
Their conduct is already a matter of record.
No reason exists for the Board to delay im-position of sanctions on the intervenors for their unjustified disregard of the discovery orders and schedule imposed by the Board.
8011050171 C
J
2.
Yesterday, General Electric received from the NRC Staff an advance copy of what purports to be the newly promulgated Part 72.
This is the first opportunity General Electric has had to study the regulations under which its license renewal application will now be reviewed.
In order to proceed in this matter in an orderly and expedious manner General Electric proposes that it submit to this Board. within 2 weeks from the date of this filing, on November 13, 1980, a revised schedule for proceeding in this matter under Part 72.
The schedule, as it is envisioned, will permit General Electric, to make what changes or additions, if any, are required under Part 72 to documents, including the Con-solidated Safety Analysis Report submitted as part of General Electric's application for renewal of SNM-1265.
The schedule will also permit a period of time for the Intervenors and the NRC Staff to review the additional or changed documents prior to resumption of the proceeding.
For both these reasons Illinois' Motion To Stay Proceedings should be denied and General Electric should be granted permission to suggest a revised schedule to this Board by November 13, 1980.
Respectfully submitted, GENERAL ELECTRIC CO.
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Ronald W.
Szwajkowski Matthew A.
Rooney OF COUNSEL:
Its Attorneys MAYER, BROWN & PLATT 231 South LaSalle Street Chicago, Illinois 60604 (312) 782-0600.
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION t
In the Matter of
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GENERAL ELECTRIC COMPANY
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Docket No. 70-1308 Consideration of Renewal of
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Materials License No. SNW-1265)
Issued to GE Morris Operation )
Fuel Storage Installation
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4 CERTIFICATE OF SERVICE 1
The undersigned hereby certifies that he served a copy i
of ANSWER OF GENERAL ELECTRIC TO MOTION TO STAY PROCEEDINGS OF THE STATE OF ILLINOIS, in the above-captioned pro-ceeding on the following persons by causing the said copies to be deposited in the United States mail at 231 South LaSalle Street, Chicago,. Illinois, in plainly 1
addressed and sealed envelopes with proper first class postage attached before 5:00 P.M. on October 30, 1980:
Andrew C. Goodhope, Esq., Chairman Susan N.
Sekuler, Esq.
Atomic Safety and Licensing Board George William Wolff, Esq.
3320 Estelle Terrace Office of the Attorney General Wheaton, Maryland 20906 188 West Randolph Street.
Suite 2315 Dr. Linda W.
Little Chicago, Illinois 60601 Atomic Safety and Licensing Board 5000 Hermitage Drive Marjorie Ulman Rothschild, Esq.
Raleigh, North Carolina 27612 United States Nuclear Regulatory Commission Dr. Forrest J.'Remick washington, D.C.
20555 Atomic Safety and Licensing Board 305. East Hamilton Avenue Atomic Safety and Licensing State College, Pennsylvania 16801.
Board Panel
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U.S.
Nucler.r Regulatory Atomic Safety sn'd Licensing Appeal Commission J
Panel Washington, D.C.
20555 U.S. Nuclear Regulatory Commission Washington,ED.C.
20555 Docketing and Service Section Office of the Secretary Bridget L. Rorem U.S.
Nuclear Regulatory Essex, Illinois 60935' Commission Washington, D.C.
20555 Everett~J. Quigley R. R.
1,- -Box 378 Kankakee, Illinois 60901
,y Matthew A. Rooney, j/
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